Filing 105

NOTICE of Proposed Order Regarding the Schedule for Completion of Discovery by PUBLIC.RESOURCE.ORG, INC. re Set/Reset Deadlines (Attachments: #1 Text of Proposed Order Regarding the Schedule for Completion of Discovery)(Bridges, Andrew)

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA AMERICAN SOCIETY FOR TESTING AND MATERIALS d/b/a ASTM INTERNATIONAL; Case No. 1:13-cv-01215-TSC-DAR NATIONAL FIRE PROTECTION ASSOCIATION, INC.; and PUBLIC.RESOURCE.ORG, INC.’S NOTICE OF FILING WITH PROPOSED ORDER REGARDING THE SCHEDULE FOR COMPLETION OF DISCOVERY AMERICAN SOCIETY OF HEATING, REFRIGERATING, AND AIR CONDITIONING ENGINEERS, Plaintiffs/Counter-defendants, Filed: August 6, 2013 v. PUBLIC.RESOURCE.ORG, INC., Defendant/Counterclaimant. Public.Resource.Org hereby provides notice to the Court of the attached proposed order, in response to the Court’s Orders of June 10 and June 16, 2015. Public Resource has met and conferred with Plaintiffs on three occasions in the past week-and-a-half and exchanged numerous emails in an effort to reach an agreement. Public Resource has also offered Plaintiffs an additional one to two weeks to take the deposition of Public Resource’s expert, whose deposition Plaintiffs noticed only this afternoon, but Plaintiffs have declined that offer. Accordingly, the proposed order is attached. Respectfully submitted, Dated: June 24, 2015 /s/ Andrew P. Bridges Andrew P. Bridges (admitted) Kathleen Lu (pro hac vice) Matthew B. Becker (pro hac vice) FENWICK & WEST LLP 555 California Street, 12th Floor San Francisco, CA 94104 Telephone: (415) 875-2300 Facsimile: (415) 281-1350 David Halperin (D.C. Bar No. 426078) 1530 P Street NW Washington, DC 20005 Telephone: (202) 905-3434 Mitchell L. Stoltz (D.C. Bar No. 978149) Corynne McSherry (pro hac vice) ELECTRONIC FRONTIER FOUNDATION 815 Eddy Street San Francisco, CA 94109 Telephone: (415) 436-9333 Facsimile: (415) 436-9993 Attorneys for Defendant-Counterclaimant Public.Resource.Org, Inc. 2

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